The Occupational Safety and Health Administration (OSHA) Code of Federal Regulations lists numerous types of training, with various exceptions and provisions. However, general knowledge of a few simple laws and conditions can help you understand the requirements for OSHA training.
OSHA has extensively researched the correlation between training employees and a safe working environment. Many work-related injuries could have been prevented or greatly reduced in severity by instructing employees on less hazardous practices. So OSHA developed training standards, also called regulations(CFRs), and enforces them with citations and penalties.
Most OSHA training is divided into four major sections: initial; annual; specific increments (such as every three years); and when changes or new hazards occur. Typically, even if a law allows for several years between training, it's likely your employees will need more frequent training because of the potential for new hazards.
One constant in OSHA law is that all employees are to be trained on the hazards of their jobs before they start work; this applies to new employees as well as those who change jobs or begin new tasks covered under OSHA. An example of this initial training is the powered industrial truck laws, which state that no untrained employee is to operate a forklift without preliminary training on the potential hazards of the vehicle.
Annual and Specific Increment Training
After an employee has initial training, employers must consult the Code of Federal Regulations for annual or specific increment requirements. Generally speaking, workers who are exposed to greater potential harm have more frequent retraining. Employees who work with respirators and bloodborne pathogens, such as hepatitis B, hepatitis C and HIV/AIDS, have clearly stated annual retraining requirements because there's potential for significant harm if training is forgotten.
Some laws allow for retraining every three years, but it's important to note that there's an extensive paragraph of exceptions listed in each standard. These allow for more frequent retraining if a potential hazard presents itself. Some exceptions that merit additional training are when a new danger, accident or near-miss incident is identified. Nearly all OSHA training areas are affected by these criteria. For instance, if an employee is injured in a forklift accident, all forklift drivers must be immediately retrained.
Other special hazards that affect the frequency of training are a change in processes or job duties and adding new chemicals or equipment. Hazard communication training indicates that employees are to receive chemical training before employment. No annual or specific time frame retraining is required unless an employer adds new potentially hazardous chemical procedures.
Employers are required to review written programs annually. Vital parts of those evaluations include discovering new hazards or processes and identifying potential dangers. If an employer notices any changes, affected workers should be retrained. Written program reviews are an excellent way to stay on top of current training needs at your facility, and ultimately to maintain a safer workplace.
Leanne Coffman has worked since 2004 as a writer, consultant and expert witness for litigation. She facilitates training programs for management and staff of international hospitals and national companies in physical and technical security, emergency procedures, disaster response, workplace and fire safety and OSHA/HSE compliance. Coffman is a licensed training provider for the American Red Cross and Subject Matter Expert for multiple sources.